Additional Region-Specific Information

Certain regions, countries and U.S. states have enacted privacy laws that require that we provide residents of those locations with additional information not found in the main Privacy Notice, including information on location-specific choices or rights.  You can learn more about your rights and choices for the following locations in this section, including the effective dates of certain rights.

 


Region-Specific Information

California Notice of Collection of Personal Information: This notice to California residents is provided under California law, explains your privacy rights as a California resident, provides our “notice at collection,” and provides certain mandatory disclosures about our treatment of California residents’ personal information, both online and offline.

The information in this section applies to the personal information we’ve collected from California residents during the 12 months prior to the effective date of this Privacy Notice.

The following table describes the categories of Personal Information that Viasat collects, the sources from which the Personal Information is collected and the categories of third parties to whom Personal Information is disclosed.

 

Categories of Personal Information

Personal Information Sources

Categories of Recipients

Identifiers (name, contact information, unique identifiers, cookies, IP address, and other similar identifiers)

  • You (directly and indirectly)
  • Third-party (data broker)
  • Viasat group companies
  • Third-party service providers
  • Credit agencies or bureaus
  • Payment processors
  • Business partners
  • Third-party ad networks
  • Law enforcement and related entities

Any personal information described in subdivision (e) of Section 1798.80, e.g., personal records such as financial and related information, and bank account information, e.g., to set up direct debit payments

  • You (directly)
  • Payment Processor
  • Viasat group companies
  • Third-party service providers
  • Credit agencies or bureaus
  • Payment processors
  • Business partners

Characteristics of protected classifications under California or federal law (age, gender, and other demographic data)

  • You (directly)
  • Third-party data broker
  • Viasat group companies
  • Third-party service providers

Commercial information (your service usage information, history and preferences; purchase history)

  • You (directly and indirectly)
  • Third-party data broker
  • Viasat group companies
  • Third-party service providers
  • Law enforcement and related entities

Internet or other electronic network activity information (your online usage information and online interactions with the Services)

  • You (indirectly, including your device)
  • Third party (airline or other transportation partner)
  • Viasat group companies
  • Third-party service providers

Professional or employment-related information (as part of the characteristics information we collect about you)

  • Third-party data broker
  • Viasat group companies
  • Third-party service providers

Geolocation data such as country and zip code

  • You (directly and indirectly)
  • Third-party data broker
  • Viasat group companies
  • Third-party service providers
  • Law enforcement and related entities

Audio, electronic, visual, thermal, olfactory, or similar information such as recordings of customer service calls

  • You (indirectly)
  • Viasat group companies
  • Third-party service providers

Inferences drawn from the above categories (inferences we draw from your information and activity through the Services to help create a personalized profile so we can better identify services that may be of interest)

  • You (directly and indirectly) Third-party data broker
  • Viasat group companies
  • Third-party service providers

 

Sensitive Personal Information

  • You (directly)
  • Viasat group companies
  • Third-party service providers

 

Our specific business and commercial purposes for collecting your personal information is described in the “How We Use Your Personal Information and our Legal Bases” section of the Privacy Notice.

We may retain each category of personal information we collect as long as necessary to provide our Services to you, after which we delete your data in accordance with our corporate retention policy. For more information, please see the “How Long We Keep Your Information” section of the Privacy Notice. 

Categories of Personal Information Sold or Shared

In the last 12 months, we “sold” or “shared” (as these words are defined under California law) the following categories of personal information to vendors of services related to advertising (such as ad platforms or networks), marketing, analytics, and measurement for commercial purposes, such as the marketing and advertising of our Services:

  • Identifiers
  • Internet or other electronic network activity information

We do not sell or share the personal information of known consumers under 16 years of age.

 

Use and Disclosure of Sensitive Personal Information:

To the extent that we collect, use, or share “sensitive personal information” as that term is defined under California law, we limit our use or disclosure of the sensitive personal information to permitted business purposes.

 

California Privacy Rights

(a) Right to Access

You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share, such information to be provided to you in a readily useable format.

(b) Right to Delete

You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

(c) Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

(d) Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to opt-out of the “sale” or “sharing” of your personal information, as such terms are defined under California law.

(e) Right to Non-Discrimination

You have the right not to be treated in a discriminatory manner for exercising your privacy rights. We do not use the fact that you have exercised or requested to exercise any rights for any purpose other than facilitating a response to your request.

(f) Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to limit our use and disclosure of sensitive personal information, such as your credit card information with security code, where we use such information to draw inferences or for nonpermitted purposes under California law.  We limit our use or disclosure of sensitive personal information to permitted business purposes.  

 

Exercising your California Privacy Rights

To exercise your rights, please visit our Privacy Rights Request Form or call us at 1-855-463-9333.

Requests to Opt-Out of the “Sale” or “Sharing” of Personal Information: To submit a request to opt-out of the sale or sharing of your personal information, you may click on the “Do Not Sell or Share My Personal Information” link or you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control. We will process such a signal as a request to opt-out. 

To process certain rights requests described in this section, we may need to verify that you are the person that is the subject of the request. This verification process consists of matching identifying information provided by you with the information we have about you in our records. When making a request, you may be asked to provide your name, email address, contact and request details. A confirmation email will be sent to the email address you provide. If we cannot verify your identity, we may not be able to respond to your request.  We use the information that we collect about you during the verification process only for verification purposes.

 

Instructions for Authorized Agents Making Requests

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents may submit a request using the Privacy Rights Request Form and will need to demonstrate that you’ve authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using a consumer’s personal information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention. 

We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

 

California Consumer Privacy Act (CCPA) Metrics

Under CCPA, businesses that process these requests must publish information about them. That information for California residents for the period of January 1, 2023 through December 31, 2023 is below.

 

Access Requests

Total number of Access Requests Received

4

Total number of Access Requests complied with in whole or in part

4

Total number of Access Requests Denied

0

 

Deletion Requests

Total number of Deletion Requests Received

20

Total number of Deletion Requests complied with in whole or in part

20

Total number of Deletion Requests Denied

0

 

Do Not Sell (DNS) Requests

Total number of DNS Requests Received

0

Total number of DNS Requests complied with in whole or in part

0

Total number of DNS Requests Denied

0

 

Average Days to Respond

Average number of days to respond to Access requests

46

Average number of days to respond to Deletion requests

20

Average number of days to respond to DNS requests

N/A

 

Do Not Track

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn't an industry standard for recognizing or honoring DNT signals, we do not respond to them at this time. 

Effective July 1, 2023

 

This section provides supplemental information to residents of the State of Colorado, whose personal data we process in connection with the Services.

 

Please see the main Privacy Notice for a description of the personal data we collect, the purposes for which we use it, and how and with whom we share it.

 

Colorado Privacy Rights

 

(a) Right to Access

You have the right to know and access the personal data we process concerning you.

 

(b) Right to Delete

You have the right to delete personal data concerning you.

 

(c) Right to Opt-Out

You have the right to opt out of targeted advertising and the sale of your data (as defined under Colorado law).

 

(d) Right to Correct

You have the right to correct inaccuracies in the personal data, taking into account the nature of the personal data and the purposes of the processing.

 

(e) Right to Portability

You have the right to obtain a portable copy of the personal data we process concerning you.

 

Exercising Your Colorado Privacy Rights

 

To exercise your rights, please visit our Privacy Rights Request Form or email privacy@bwolfcustoms.com.

 

To opt-out of targeted advertising and the sale of personal data, you may visit our Privacy Rights Request Form or you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control. We will process such a signal as a request to opt-out.

 

To process your request, we may need to verify that you are the person that is the subject of the request. This verification process consists of matching identifying information provided by you with the information we have about you in our records. When making a request, you may be asked to provide your name, email address, contact and request details. A confirmation email will be sent to the email address you provide. If we cannot verify your identity, we may not be able to respond to your request.  We use the information that we collect about you during the verification process only for verification purposes.

 

Instructions for Authorized Agents Making Requests

You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents may submit a request using the Privacy Rights Request Form and will need to demonstrate that you’ve authorized them to act on your behalf or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent is prohibited from using a consumer’s personal information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention. 

 

To appeal our decision regarding a request related to these rights, you may email us at privacy@bwolfcustoms.com.

 

We do not process the personal data of children under 13 years of age.

Effective July 1, 2023

 

This section provides supplemental information to residents of the State of Connecticut, whose personal data we process in connection with the Services.

 

Please see the Privacy Notice for a description of the personal data we collect, the purposes for which we use it, and how and with whom we share it.

 

Connecticut Privacy Rights

 

(a) Right to Access

You have the right to know and access the personal data we process about you.

 

(b) Right to Delete

You have the right to delete the personal data provided by or obtained about you.

 

(c) Right to Opt-Out

You have the right to opt out of targeted advertising and the sale of your data (as defined under Connecticut law).

 

(d) Right to Correct

You have the right to correct inaccuracies in the personal data, taking into account the nature of the personal data and the purposes of the processing.

 

(e) Right to Portability

You have the right to obtain a portable copy of your data processed by us.

 

Exercising Your Connecticut Privacy Rights

 

To exercise your rights, please visit our Privacy Rights Request Form or email privacy@bwolfcustoms.com.

 

To opt-out of targeted advertising and the sale of personal data, you may visit Privacy Rights Request Form or you may choose to enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control. We will process such a signal as a request to opt-out.

 

To appeal our decision regarding a request related to these rights, you may email us at privacy@bwolfcustoms.com

Broadband internet access services

 

The Maine Broadband Internet Access Service Customer Privacy Act gives you additional privacy rights when we are your broadband Internet access service provider. The Maine law gives you the right to control certain ways that we use or share information we have about you and requires that we provide you with a notice of your rights and our obligations under this law. We do this in this section.

 

The Maine law also requires us to take reasonable measures to protect your customer personal information. We describe this in the “How We Secure Your Personal Information" section of this Privacy Notice.

 

We will not use, disclose, sell, or permit access to your broadband customer personal information except for purposes allowed under the Maine law or with your affirmative consent. We may ask you for this consent when we interact with you. For example, we may ask to use your broadband customer personal information to market additional non-communications-related services to you when you contact us.

 

The Maine law also provides you with a right to opt-out of any use or sharing of data that is not customer personal information under the law that we may collect. If you have questions about your rights, or to exercise your rights under the law, please contact us at privacy@bwolfcustoms.com. We will not refuse to provide you with broadband service, charge you a penalty, or offer you a discount based on whether you agree that we can use or share your broadband customer personal information.

The Categories of Personally Identifiable Information We Collect Through Our Website and Online Services

 

For information about the categories of Personally Identifiable Information we collect through our website and online, please see the “Personal Information We Collect and Sources of Information” section of our Privacy Notice.

 

The Categories of Third Parties with Whom We Share Personally Identifiable Information

 

For information regarding the categories of third parties with whom we may share your personally identifiable information, and those that may collect personally identifiable information regarding your online activities over time, please see the “When We Share Your Personal Information section of our Privacy Notice.

 

Opt-out Requests

We do not sell your personally identifiable information, as “sale” is defined under Nevada law. Nonetheless, Nevada law allows you to submit a request directing us not to sell any personally identifiable information we have collected or will collect from you. If you wish to submit a request, please visit our Privacy Rights Request Form

 

How We Notify You of Changes to Our Privacy Policy

 

Please see the “Updates to this Privacy Notice” section of our Privacy Notice.

Effective December 31, 2023

 

This section provides supplemental information to residents of the State of Utah, whose personal data we process in connection with the Services.

 

Please see the Privacy Notice for a description of the personal data we collect, the purposes for which we use it, and how and with whom we share it.

 

Utah Privacy Rights

 

(a) Right to Access

You have the right to know and access the personal data we process about you.

 

(b) Right to Delete

You have the right to delete the personal data you provided to us.

 

(c) Right to Opt-Out

You have the right to opt-out of targeted advertising (as defined under Utah law). We do not sell personal data as “sale” is defined under Utah law.

 

(d) Right to Portability

You have the right to obtain a portable copy of the personal data you provided to us.

 

Exercising Your Utah Privacy Rights

 

To exercise your rights, please visit our Privacy Rights Request Form or email privacy@bwolfcustoms.com.

 

To opt-out of targeted advertising, you may visit Privacy Rights Request Form.

Effective January 1, 2023

 

This section provides supplemental information to residents of the State of Virginia, whose personal data we process in connection with the Services.

 

Please see the Privacy Notice for a description of the personal data we collect, the purposes for which we use it, and how and with whom we share it.

 

Virginia Privacy Rights

 

(a) Right to Access

You have the right to confirm whether we are processing your personal data and to access such personal data.

 

(b) Right to Delete

You have the right to delete personal data provided by or obtained by you.

 

(c) Right to Opt-Out

You have the right to opt out of targeted advertising (as defined under Virginia law). We do not sell personal data as “sale” is defined under Virginia law.

 

(d) Right to Correct

You have the right to correct inaccuracies in the personal data, taking into account the nature of the personal data and the purposes of the processing.

 

(e) Right to Portability

You have the right to obtain a portable copy of the personal data that you provided to us.

 

Exercising Your Virginia Privacy Rights

 

To exercise your rights, please visit our Privacy Rights Request Form or email privacy@bwolfcustoms.com.

 

To appeal our decision regarding a request related to these rights, you may email us at privacy@bwolfcustoms.com.

1.       Joint control of EU data

 

For Viasat’s global fixed broadband service available in Spain and Italy, Viasat Europe Sàrl in Switzerland contracts with certain Viasat customers whose personal data is within the scope of GDPR, UK GDPR and Swiss Data Protection Law, all as amended from time to time (“EU Data”).  Viasat, Inc. and Viasat Europe Sàrl jointly control EU Data.

 

As between Viasat, Inc. and Viasat Europe Sàrl, Viasat, Inc. is the main decision maker as to the processing of EU Data and is primarily responsible for fulfilling the controller responsibilities with respect to EU Data, with assistance from Viasat Europe Sàrl where required.  For example, Viasat, Inc. is the primary decision maker regarding what and why EU Data is collected, how it is used, how long it is retained and other decisions regarding it and, as between it and Viasat Europe Sàrl, primarily responsible for making sure this is done in accordance with the GDPR, UK GDPR and Swiss Data Protection Law, all as amended from time to time. Viasat, Inc., as between Viasat, Inc. and Viasat Europe Sàrl, is also primarily responsible for informing you how Viasat processes your EU Data (including by providing this notice), deciding how to implement data subject requests and, where necessary, primarily engaging with data protection supervisory authorities and making notifications to them and data subjects. Viasat Europe Sàrl assists Viasat, Inc. in this regard.

 

Viasat Europe Sàrl implements the decisions of Viasat, Inc. with respect to the processing of EU Data and acts as the main establishment in the EU of Viasat, Inc. and Viasat Europe Sàrl with respect to the processing of jointly controlled EU Data.  Viasat Europe Sàrl also engages directly with customers with respect to certain functions such as billing and customer services. 

 

Viasat, Inc. is the main point of contact for data subjects with respect to EU Data so, for example, it is best to contact Viasat, Inc. if you want to exercise your data subject rights under the GDPR, UK GDPR or Swiss Data Protection Law, as amended from time to time, with respect to EU Data.  Its contact details are set out in this Notice. Irrespective of this arrangement, you can exercise your rights under the GDPR against either Viasat, Inc., or Viasat Europe Sàrl with respect to EU Data.

 

2.       Contacting Viasat

 

Viasat commits to resolve complaints about your privacy and our collection or use of your personal information.  In addition to contacting us through the How to Contact Us section of the Privacy Notice, inquiries or concerns regarding this Notice or Viasat’s data handling practices should be directed to our Data Protection Officer, using the following information:

 

European Economic Area

Fieldfisher LLP

Data Protection Officer

ViasatDPO@fieldfisher.com

 

United Kingdom

Fieldfisher LLP

Data Protection Officer

ViasatDPO@fieldfisher.com

 

You also can contact us through our representatives using the information below if you are in the UK or European Economic Area (EEA):

 

UK Representative

Lionheart Squared Ltd (FAO Viasat)

Attn: Data Privacy

17 Glasshouse Studios

Fryern Court Road

Fordingbridge

Hampshire, SP6 1QX UK

Viasat@LionheartSquared.co.uk

 

EEA Representative

Lionheart Squared Ltd (FAO Viasat)

Attn: Data Privacy

2 Pembroke House

Upper Pembroke Street 28-32

Dublín

DO2 EK84

Republic of Ireland

Email: viasat@LionheartSquared.eu

This privacy notice should be read in conjunction with our main Privacy Notice.

How We Use Your Personal Data

If you are a subscriber of any Viasat telecommunication service provided by Viasat in Brazil (“Services”), your personal data is jointly controlled by Viasat, Inc. and Viasat Brasil Serviços de Comunicações Ltda., the provider of the telecommunications services in this country.

Your personal data is primarily used to provide you with the Viasat products and services you request. It may also be used to comply with legal obligations we are subject to, bring or defend ourselves in legal claims, or to fulfill our legitimate interests, such as to personalize your experience, develop and improve our services, or detect illegal activities, which may also be done to protect your vital interests. Viasat may also process personal data for purposes of complying with applicable Federal and State laws and regulations in Brazil where our products and services are offered. With your prior consent or whenever there is a legitimate interest at stake, it may also be used to send you offers and promotions.

To the fullest extent not prohibited by applicable laws, we may disclose the personal data we collect from and about you for business and commercial purposes to the following categories of recipients: (i) Viasat group companies, (ii) third-party service providers, (iii) credit agencies or bureaus, (iv) authorized retailers and distributors, (v) third-party ad platforms or networks, (vi) entities involved in a corporate transaction, (vii) law enforcement, governmental judicial and related entities, (viii) third parties who receive aggregate or anonymous information, and (ix) other persons with our consent.

 

We may transfer your personal data outside your local territory. These international data transfers are carried out in accordance with applicable data protection legislation and with the adoption of all the necessary safeguards.

 

We will retain your personal data for the period necessary to fulfill the purposes outlined hereto and/or in our main Privacy Notice, as needed to provide Services and/or to comply with our legal obligations.

For more information about Viasat’s data collection and use practices please read our main Privacy Notice, including the information available in the “Service-Specific Privacy Information” section of this document.

Know Your Data Protection Rights

You have several rights outlined in Brazil’s data protection legislation including but not limited to the right to confirm the existence of the processing of your personal data, request access to, change, or remove your personal data, change your marketing preferences (including withdrawing your consent at any time), and to petition before the national data protection authority, as set out in Article 18 of Brazil’s General Data Protection Law and other applicable laws.

Please see our main Privacy Notice to learn more about managing your marketing preferences or deleting the account you created to access our services.

 

Contact Information for Data Protection Office

Viasat Brasil Serviços de Comunicações Ltda.

Avenida Presidente Vargas, n.º 309

21º andar, Centro

Rio de Janeiro/RJ, Brasil

CEP 20.040-010

 

Viasat, Inc.

Attn:  Viasat Privacy Office

901 K Street, NW, Suite 400

Washington, DC 20001

Our Data Protection Officer can be contacted by emailing: privacy@bwolfcustoms.com

How to Make a Request

To make a request, please visit our Privacy Rights Request Form

Data Owners from Mexico may have the following rights under the FPDL:

 

  • The right to be provided with information about how we process their information
  • The right to access their Information
  • The right to rectify Information if it is inaccurate or incomplete
  • The right to object to the processing of Information
  • The right to limit the use or disclosure of their Information
  • The right to cancel/delete their Information
  • The right to revoke consent granted for the processing of Information

 

To exercise the above rights, please visit the Privacy Rights Request Form. We will notify you within twenty (20) days of receipt of your request with a determination on your request. If more time is required to fulfill your request, we will notify you with a justification for the extension. Please be aware that under certain circumstances, the FPDL may limit your exercise of these rights.